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    <title>2025 (11) TMI 660 - SC Order</title>
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    <description>SC dismissed the special leave petitions and declined to interfere with the HC&#039;s judgment, which had held that reopening assessment under s.147 beyond four years was not justified. The Court found the reasons recorded-based on a holding company&#039;s submissions to the Settlement Commission and an alleged accommodation entry affecting WDV-to be insufficient to form a belief that income had escaped assessment, noting the claimed depreciation bore no nexus to the WDV in the books and thus could not support jurisdiction to reopen.</description>
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      <link>https://www.taxtmi.com/caselaws?id=781192</link>
      <description>SC dismissed the special leave petitions and declined to interfere with the HC&#039;s judgment, which had held that reopening assessment under s.147 beyond four years was not justified. The Court found the reasons recorded-based on a holding company&#039;s submissions to the Settlement Commission and an alleged accommodation entry affecting WDV-to be insufficient to form a belief that income had escaped assessment, noting the claimed depreciation bore no nexus to the WDV in the books and thus could not support jurisdiction to reopen.</description>
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